This English page mirrors the French reference page for international clients. It is written for decision-makers who need a clear first reading before a tailored French tax analysis.
Who is concerned?
Taxpayers who have been French tax residents for the required period and who hold assets within the statutory perimeter may be within French exit tax when transferring tax residence outside France.
Is tax always payable immediately?
No. Payment may be deferred automatically or on request depending on the destination and conditions. The difference between assessment and payment is central.
Does moving to Dubai avoid exit tax?
No. A Dubai move may be attractive from a personal tax perspective, but the French exit tax analysis remains necessary before departure.
What forms are filed?
The initial filing generally involves form 2074-ETD, with possible annual monitoring during the deferral period.
When can the tax be cancelled?
Relief may apply after the statutory holding period, on return to France, or in other situations provided by law. Each event must be documented.
Use the FAQ as a decision tree, not a filing instruction
Exit-tax questions are connected. A threshold answer is unreliable until residence history, family ownership and the nature of the assets are known. A payment-deferral answer depends on the destination and transfer date. A relief answer depends on what happened to each holding after departure. The following sequence shows which facts should be established before a general FAQ answer is applied to a real file.
1. Does the regime need to be tested?
Confirm the factual date on which French tax residence is expected to end and the number of relevant French-resident years in the statutory look-back period. List direct and household shareholdings, securities, earn-out receivables and gains already under deferral. Apply the ownership and value tests in the current Article 167 bis; do not treat every asset, bank account, property or directly held token as automatically within the exit-tax base.
2. What is valued and how?
For each in-scope interest, determine tax basis and market value at the transfer date. Listed prices may be observable, while an unquoted company requires a reasoned methodology. Recent financing can be evidence without being conclusive, particularly where investor preference rights differ from the founder's ordinary shares. Keep calculations, source accounts and assumptions with the return.
3. When is cash due?
Separate assessment from collection. Depending on the destination and current cooperation framework, payment may be immediate, automatically deferred or deferred on a timely application. An optional route can require a representative and guarantee. “Deferred” does not mean cancelled, and an automatic deferral does not mean that no filing or later event review is needed.
4. What happens after departure?
- A sale or redemption may make a deferred amount collectible, subject to the statutory computation.
- A gift, succession, reorganisation or partial disposal needs its own event analysis.
- Relief after a holding period is conditional and can differ for historic departure years.
- A return to France may support relief for components still outstanding.
- Annual and event-driven forms depend on the transfer year and type of gain.
5. Which answer should be verified first?
Start with the point that can change the entire route: residence date, scope threshold, destination classification or a transaction already scheduled. Where the move is imminent, filing and security deadlines take priority over longer-term optimisation. Where a sale is imminent, valuation and event consequences should be tested together. Where residence is uncertain, resolve that evidence before presenting a precise exit-tax figure.
The authoritative starting points are Article 167 bis CGI, BOFiP guidance and the official 2074-ETD page. Answers can change with legislation and facts; none of the short answers on this page promises a tax result.